SEPA UniMdStMM Envtromnemcl Protection Agency Off ic« of Soltd Wast* and Em*rg*ncy R*spon»* DIRECTIVE NUMBER: 9444.01(84) TITLE: Clarification of the Listings for Metal Heat Treating Wastes F010, F011, and F012 APPROVAL DATE: 3-5-84 EFFECTIVE DATE: 3-5-84 ORIGINATING OFFICE: 12 FINAL Office of Solid Waste D DRAFT STATUS: I 1 [ 1 [ ] [ A- Pending OMB approval B- Pending AA-OSWER approval C- For review &/or comment ] D- In development or circulating REFERENCE (other documents): headquarters OSWER OSWER OSWER VE DIRECTIVE DIRECTIVE Dl ------- PART 261 SUBPART D - LISTS DOC: 9444.01(84) Key Words: Cyanide Regulations: 40 CFR 261.31 Subject: Addressee: Date: Summary: Clarification of the Listings for Metal Heat Treating Wastes F010, F011, and F012 James H. Scarbrough, Chief, Residuals Management Branch, Air and Waste Management Division, Region IV Originator: Matthew A. Straus, Acting Chief, Waste Identification Branch Source Doc: #9444.01(84) 3-5-84 If a metal heat treating process uses any form of cyanide—complex or free—the process is covered by the hazardous waste listings F010, F011, and F012. ------- 9444.01 xflarificat loir' of the Listings Tor Metal Heat Treating "Wastes *010,\Fvll, and F012. v -•--.. Matthew A. Straus, Acting enter Waste Identification Branch {WH-562J *>•* " --*"' v * "James- E. Scarbrough, Chief t Residuals Management Branch Air & Waste Management Division Region IV " '* "" This memorandum is in response to your question regarding the scope of the cyanide listings for metal heat treating operations (EPA Hazardous Waste Nos. P010, F011, and P012). In particular, you asked whether the form of cyanide (i.e., complex cyanide or free cyanide) was germane in determining whether one had a listed waste. In short, the answe-F^ls no. In listing these'wastes as hazardous, the Agency was (and is still) concerned with the management (or mismanagement) of cyanide wastes (both complex cyanide mnd cyanide salts). If the Agency felt that a distinction was necessary, it would have done so in the listing. For example., SPA Hazardous Waste No. F012 would have been listed 'as follows:" V . . " ,"Quenching wastewater treatment sludges from metal • . heat treating operations where complexed cyanides are . -. ..used in the process (except for precious metals heat '... /treating quenching wastewater treatment sludges)." - In addition, you should be aware .that the form of cyanide often changes during the heat treating operation or subsequent treatment; therefore, although you may begin with cyanide salts (free cyanide) your waste may be primarily Complex cyanide. The waste listings take this into, account by differentiating between the form of cyanide present in the waste (i.e., .only cyanide-salt containing wastes (free •.cyanides) are listed as posing a reactivity hazard). •. - • - , ...• . ^ . •.-.•-.... • . .»/ • '. • - ,- * X"' • ' T" «' J" -Furthermore, it should be noted that although complex cyanides'are less toxic than free1 cyanides, complex cyanide- ••» bearing wastes are of concern because of their potential to undergo photodecomposition to form toxic hydrogen cyanide and free cyanide decomposition by-products. (See Listing Background Document for Cyanide Wastes, Response to Cerements Section, Comment No. 3 for more details.)!./ Therefore, if the metal heat treating process uses cyanides in any form, the process is covered by the hazardous waste listings. V This document is included in the document $$261.31 and 261.32 - Listing of Hazardous Wastes (Pinalization of May 19, 1980 Hazardous Waste List), #1941.28 November 14, 1980. ------- |